Entities Ask FCC to Seek Details on C-Band Proposals

The American Cable Association, the National Association of Broadcasters, NCTA, and National Public Radio, Inc., jointly asked the FCC today to include a plethora of questions in a draft 3.7–4.2 gigahertz C-band notice of proposed rulemaking that is expected to be circulated next week for consideration at the agency’s July 12 meeting.

Meanwhile, at an event today, representatives of various interests in the proceeding debated a proposal to allow satellite operators to repurpose 100 megahertz of the band for terrestrial mobile use through a market-based framework and another plan to open up at least some of the band for fixed point-to-multipoint use.

Last month, FCC Chairman Ajit Pai announced that he will ask his fellow Commissioners to consider at the July 12 meeting “a proposal to make more intensive use of that 500 MHz of spectrum, including seeking additional input on making it available for commercial terrestrial use” (TR Daily, May 23).

Last summer, the FCC adopted a notice of inquiry to explore freeing up frequencies between 3.7 GHz and 24 GHz for 5G services (TR Daily, Aug. 3, 2017). The NOI solicited comment on three specific bands: the 3.7–4.2 GHz and 5.925-6.425 GHz bands (which are known as the conventional C-band), and the 6.425–7.125 GHz band. It also sought views on other non-federal mid-band frequencies.

The proceeding has pitted a variety of interests against each other, including mobile wireless carriers, satellite interests, cable TV providers and broadcasters, tech companies, fixed wireless interests, and public safety entities.

Regarding the C-band, Intelsat License LLC, SES Americom, Inc., and Intel Corp. are pushing a market-based proposal for freeing up 100 MHz plus 50 MHz of guard band frequencies at the bottom of the C-band for mobile terrestrial use.

The Broadband Access Coalition (BAC), which has asked the FCC to adopt regulations to create a new licensed, point-to-multipoint fixed wireless service in the 3.7–4.2 GHz band, says the FCC should adopt rules that combine its proposal for use of the 3.7–4.2 GHz band with that of the market-based proposal. Google LLC also wants the FCC to adopt rules to allow point-to-multipoint use of the band.

Meanwhile, an ad hoc coalition that calls itself the Mid-Band Spectrum Coalition has sought access to the 3.7–4.2 GHz band for licensed mobile services and to the 6 GHz band spectrum for unlicensed usage.

In their ex parte filing today in GN dockets 17-183 and 18-122, ACA, NAB, NCTA, and NPR argued that the FCC’s record in the proceeding makes “clear that much more information is required before the Commission can make an informed decision on expanding terrestrial wireless broadband access in the 3.7–4.2 GHz band (C-band). As the Commission prepares a Notice of Proposed Rulemaking in the coming weeks, the undersigned organizations representing television and radio broadcasters, content providers, and cable operators — the largest end-users of C-band spectrum — urge the Commission to ask questions that explore in more detail: (1) how the various proposals for expanding terrestrial wireless use of the band would work as a technical matter, while enabling the continued provision of services that rely on C-band today to American households and businesses without interruption or technological constraint; (2) how such proposals would impact the quality and cost of video and audio programming delivered to Americans, and the day-to-day operations and costs of existing users of C-band spectrum, including C-band satellite customers and earth station owners and operators; and (3) if the proposals result in higher prices for C-band users, how they will be compensated for this additional cost.”

The filing proposes dozens of questions for the FCC to ask to get more details about how terrestrial use of the C-band would work.

For example, regarding repacking of the spectrum, the entities say the FCC should ask about mitigation of any interference, including the use of filters, out-of-band emission limits, and exclusion zones; how much spectrum would remain available for incumbent services; whether repacking would impact video and audio distribution resiliency and reliability; and how C-band operators and customers would be reimbursed if the FCC auctions any of the C-band channels.

Regarding alternative distribution questions, the entities said the FCC should seek details on what alternative arrangements would be available, whether C-band earth stations would have to be modified or new ones deployed, and what the additional costs of alternatives would be.

Regarding spectrum sharing, among the questions proposed are what steps would have to be taken to enable co-channel sharing, whether the presence of fixed or mobile wireless operations would impact C-band repacking, and whether exclusion zones would be necessary to protect incumbents from interference.

During an event this afternoon organized by the New America Foundation’s Open Technology Institute, stakeholders in the FCC’s C-band proceeding debated the market-based proposal and the proposal to permit fixed point-to-multipoint operations in the band.

Andrew Clegg, spectrum engineering lead for Google, argued that it would be “very simple” for fixed point-to-multipoint operations to share the C-band with fixed-satellite service (FSS) earth stations by ensuring that fixed antennas are not pointed at the earth stations, but he said fixed services would not be able to share the band with mobile services.

He said that more than 100 million Americans have 20 or fewer registered FSS earth stations within 100 kilometers of where they live, although he acknowledged that not all earth stations are registered. He said the fixed services could deliver broadband services to rural and other underserved areas.

“We’re ready to go. We have the equipment . We have the engineering,” Mr. Clegg said, adding that “some minor tweaks to the FCC’s rules” are necessary.

But Hazem Moakkit, vice president-spectrum strategy for Intelsat, called Mr. Clegg’s explanation for sharing between fixed service and FSS earth stations “too simplistic.”

He touted the market-based proposal, in which a satellite consortium would handle the repurposing of the bottom 100 MHz of the C-band, plus an additional 50 MHz for guard bands, for mobile broadband services. “We could potentially do more in the future,” he said.

The market-based framework, under which the consortium would address any interference issues, would enable the spectrum to be cleared in 18 to 36 months, much more quickly than if the FCC auctioned the spectrum, Mr. Moakkit said. Mr. Moakkit also said that the number of earth stations shouldn’t be used “as a proxy for occupancy,” saying that not all earth stations are registered and that the C-band is heavily utilized for critical services, such as the delivery of video programming to more than 100 million U.S. homes.

But Ross Lieberman, senior vice president–government affairs for ACA, said his group has concerns about both of the C-band proposals.

“Both of these ideas have their issues that need to be aired out and we need to fully understand,” he said, stressing the importance of the C-band to multichannel video programming distributors (MVPDs), particularly small ones like his members. Video programming distribution options other than the C-band are expensive and inefficient, he said.

Michele Farquhar, counsel to SES, echoed the benefits of the market-based proposal and suggested that the fixed wireless plan “might be piling on too much in the band,” which could lead to interference to incumbents. She said technical studies on how the fixed plan would work are necessary.

Jill Canfield, VP–legal and industry and assistant general counsel of NTCA, which is a BAC member, stressed the potential benefits of fixed wireless spectrum to her members, while stressing that, as MVPDs, they want to ensure there isn’t interference. She also said the satellite market-based plan is “really just a push to get spectrum into the hands of the Big 3 [wireless carriers], and that leaves our members out and it leaves the rural consumer out.”

Chris Wieczorek, director–spectrum policy for T-Mobile US, Inc., said that the satellite plan is faulty in that it only envisions clearing 100 MHz for wireless carriers. “100 MHz is just not a lot of spectrum in my mind,” he said. He also said that “linear television is dying” with the rise of over-the-top offerings — a contention that Mr. Lieberman disagreed with.

Jaime Fink, chief technology officer and co-founder of Mimosa Networks, Inc., an organizer of the BAC, said that realistically, wireless carriers will not use the C-band to deliver 5G services in rural areas and that fixed wireless use of the band could deliver such offerings. He also stressed that “we are 100% here to protect the satellite industry.” —Paul Kirby, [email protected]

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